Modern Slavery Statement

EFFECTIVE DATE: OCTOBER 2022

“All human beings are born free and equal in dignity and rights. They are endowed with reason and conscience and should act towards one another in a spirit of brotherhood.” – World Health Organization.

I. Introduction

The Modern Slavery Act 2015 require manufacturers and retailers doing business in the United Kingdom supplying goods or services, with an annual revenue exceeding £36 million, to disclose information regarding their policies to eradicate slavery and human trafficking from their supply chains and within their businesses.

This statement is made on behalf of Fireblocks, Ltd. and its subsidiaries (“Fireblocks”) and sets out its actions taken to understand the potential risk of modern slavery and steps taken to prevent slavery or human trafficking in our own business, and that in so far as possible, our vendors hold the same ethos.

This statement will be reviewed annually or as required.

II. Company Purpose, Structure, and Supply Chains

Fireblocks was established in 2018 and has grown to become the gold standard in virtual asset self-storage Company. We are an enterprise-grade platform delivering a secure infrastructure for moving, storing, and issuing digital assets. We enable exchanges, lending desks, custodians, banks, trading desks, and hedge funds to securely scale digital asset operations through the Fireblocks Network and MPC-based Wallet Infrastructure.

Fireblocks serves over 1,500 financial institutions, has secured the transfer of over $3 trillion in digital assets, and has a unique insurance policy that covers assets in storage & transit. Some of the biggest trading desks have switched to Fireblocks because it’s the only solution that CISOs and Ops Teams both love.

Fireblocks global headquarters are in New York, New York, and it has regional offices located in the USA, Israel, United Kingdom, and Singapore. The Company employs approximately 600 persons worldwide as of 31st July 2022.

We do not manufacture goods, operate factories, or handle raw materials or commodities. The Company does source products and services from suppliers globally. The primary supply chain categories include marketing and advertising, information technology, office services, professional services, and consumer benefits.

III. Company Statement and Principles

Modern Slavery is a criminal offence and a violation of fundamental human rights. This behaviour is not tolerated at Fireblocks.

Fireblocks is committed to conducting business in an ethical and responsible manner, and protecting human rights in the UK and overseas. This position includes respecting internationally recognized human rights wherever the Company conducts business operations. Fireblocks strongly believes that human rights are fundamental rights and freedoms that all people are entitled to, regardless of race, sex, nationality, ethnicity, language, religion, or any other status. These rights are detailed in the International Bill of Human Rights and other international treaties and instruments. Our approach to human rights risks is informed by international standards and industry best practice.

The Company believes in the ethical trade, freedom of association and the recognition of employee rights to participate in collective bargaining. As a Company, we value diversity, equality and challenge discrimination. Fireblocks stands for the eradication of all forms of forced / compulsory labor, child labor, human trafficking, and discrimination in respect of employment and occupation and does not use unpaid labour.

We recognize that as a company, there is still more we can do, and so, we will undertake a number of initiatives in this coming year.

IV. Training

Training is an essential component in raising awareness and communicating Company expectations on employee behavior in helping prevent slavery and human rights abuses. The Company provides training to personnel on Modern Slavery to help build capacity to identify, manage and deal with risks of modern slavery.

This statement is made in support of the principles of the Modern Slavery Act 2015, and basic human rights globally. It has been approved by the Fireblocks Board of Directors on October 27, 2022.